`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`CISCO SYSTEMS, INC. and QUANTUM CORPORATION,
`Petitioners,
`
`v.
`
`CROSSROADS SYSTEMS, INC.,
`Patent Owner.
`________________
`
`Case IPR2014-01544
`Patent 7,051,147
`
`________________
`
`AFFIDAVIT OF CLEMENT S. ROBERTS IN SUPPORT OF
`PETITIONERS’ UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION
`
`________________
`
`CISCO et al. v. CROSSROADS
`CQ-1013 / IPR2014-01544
`Page 1 of 4
`
`
`
`Affidavit Of Clement S. Roberts in Support of Petitioners’
`Unopposed Motion for Pro Hac Vice Admission
`
`IPR2014-01544
`U.S. Pat. No. 7,051,147
`
`I, Clement S. Roberts, being duly sworn and upon oath, hereby attest to the
`
`following:
`
`i.
`
`I am a member in good standing of the Bar of California (#209203), as
`
`well as the following Federal Courts:
`
`a) U.S. Court of Appeals for the Second Circuit;
`
`b) U.S. Court of Appeals for the Federal Circuit;
`
`c) U.S. District Court for the Northern District of California;
`
`d) U.S. District Court for the Central District of California; and
`
`e) U.S. District Court for the Southern District of California.
`
`ii.
`
`I have not been suspended or disbarred from practice before any court or
`
`administrative body.
`
`iii.
`
`I have never had an application for admission to practice before any court
`
`or administrative body denied.
`
`iv. No sanction or contempt citation has been imposed against me by any
`
`court or administrative body.
`
`v.
`
`I have read and will comply with the Office Patent Trial Practice Guide
`
`and the Board’s Rules of Practice for Trials set forth in part 42 of the
`
`Code of Federal Regulations.
`
`- 1 -
`
`CQ-1013 / IPR2014-01544
`Page 2 of 4
`
`
`
`Affidavit Of Clement S. Roberts in Support of Petitioners’
`Unopposed Motion for Pro Hac Vice Admission
`
`IPR2014-01544
`U.S. Pat. No. 7,051,147
`
`vi.
`
`I will be subject to the USPTO Rules of Professional Conduct set forth in
`
`37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R.
`
`§ 11.19(a).
`
`vii.
`
`In the last three years I have applied to appear pro hac vice before the
`
`Office in four proceedings:
`
`a) Netflix, Inc., v. OpenTV, Inc., IPR2014-00252;
`
`b) Netflix, Inc., v. OpenTV, Inc., IPR2014-00267;
`
`c) Netflix, Inc., v. OpenTV, Inc., IPR2014-00269; and
`
`d) Cisco Systems, Inc., et al. v. Crossroads Systems, Inc.,
`
`IPR2014-01226.
`
`I am concurrently applying to appear pro hac vice before the Office in the
`
`following proceeding:
`
`a) Cisco Systems, Inc., et al. v. Crossroads Systems, Inc.,
`
`IPR2014-01463.
`
`viii.
`
`I am an experienced litigation attorney, with experience in many
`
`litigations involving patent infringement in District Courts across the
`
`country, including experience with fact and expert document and
`
`deposition discovery, claim construction, Markman hearings, motion
`
`- 2 -
`
`CQ-1013 / IPR2014-01544
`Page 3 of 4
`
`
`
`Affidavit Of Clement S. Roberts in Support of Petitioners’
`Unopposed Motion for Pro Hac Vice Admission
`
`IPR2014-01544
`U.S. Pat. No. 7,051,147
`
`practice, trials and hearings, and investigations before the International
`
`Trade Commission.
`
`ix.
`
`I am counsel for Petitioner Quantum Corporation, the defendant in an on-
`
`going litigation in which U.S. Patent No. 7,051,147 is asserted by the
`
`Patent Owner. I am familiar with the subject matter at issue in this
`
`proceeding as a result of my representation of Quantum Corporation in
`
`the related litigation, including the prior art that Petitioners present in this
`
`proceeding, as well as issues of claim construction.
`
`Date: April 2, 2015
`
`________________________
`Clement S. Roberts
`DURIE TANGRI LLP
`217 Leidesdorff Street
`San Francisco, CA 94111
`Telephone: (415) 362-6666
`Fax: (415) 236-6300
`Email: CRoberts@durietangri.com
`
`- 3 -
`
`CQ-1013 / IPR2014-01544
`Page 4 of 4
`
`